How to Complete FBAR Form 114: Line-by-Line Instructions

How to complete FBAR form 114 is the process of reporting foreign bank and financial accounts exceeding $10,000 in aggregate during the calendar year. U.S. persons must file electronically via FinCEN’s BSA E-Filing system to comply with the Bank Secrecy Act and avoid severe penalties.

Key Takeaways

• FBAR filing is required if aggregate foreign accounts exceed $10,000 at any time.
• Deadline: April 15, with automatic extension to October 15.
• Penalties: Non-willful up to $10,000; willful up to $100,000 or 50% of account balance.
• FBAR (FinCEN Form 114) is separate from IRS Form 8938.
• All filings must be submitted electronically via BSA E-Filing.

The Foreign Bank Account Report (FBAR), formally known as FinCEN Form 114, is a cornerstone of U.S. international tax compliance. Required under 31 CFR § 1010.350, it obligates U.S. persons to disclose foreign financial accounts when the aggregate value exceeds $10,000 at any point during the year. Unlike IRS tax forms, FBAR is filed directly with the Financial Crimes Enforcement Network (FinCEN) through the BSA E-Filing system. This requirement stems from the Bank Secrecy Act (BSA), designed to combat money laundering, tax evasion, and illicit financial flows.

For expatriates, CFOs, and high-net-worth individuals, FBAR compliance is not optional—it is a legal mandate. Failure to file can trigger severe civil and criminal penalties, including fines and imprisonment. Understanding the nuances of FBAR filing is critical to safeguarding assets and ensuring compliance remediation strategies are in place.

Who Must File FBAR Form 114?

The obligation to file FBAR applies broadly to “U.S. persons,” a term encompassing:

• U.S. citizens and residents (including green card holders).
• Domestic entities such as corporations, partnerships, and LLCs.
• Trusts and estates formed under U.S. law.

Two primary categories trigger filing:

1. Financial Interest: Direct ownership or control of a foreign account.
2. Signature Authority: The ability to control account disposition, even without ownership.

The threshold is clear: if the aggregate value of all foreign accounts exceeds $10,000 at any time during the calendar year, FBAR filing is mandatory. This includes bank accounts, brokerage accounts, mutual funds, and certain pension accounts. Dormant accounts, even those with negligible balances, must be reported if they contribute to crossing the threshold.

Example: A U.S. resident with three accounts in Singapore totaling $9,500 and a dormant account in Switzerland with $600 must file FBAR, as the aggregate exceeds $10,000.

Statutory citation: 31 CFR § 1010.350(b) explicitly defines the reporting obligation for U.S. persons with foreign financial accounts.

Filing Deadlines & Extensions

The FBAR filing deadline aligns with the U.S. tax calendar:

• Standard Deadline: April 15 of the following year.
• Automatic Extension: To October 15, no separate request required.

Missing the deadline can result in significant penalties. However, the IRS recognizes compliance remediation pathways, such as the Delinquent FBAR Submission Procedures, for taxpayers who inadvertently fail to file. Voluntary disclosure programs may mitigate penalties but require proactive action.

Hypothetical Scenario: A taxpayer discovers in July that they failed to file FBAR for the prior year. By using the automatic extension to October 15, they can still file without penalty. If discovered after October, they may need to pursue voluntary disclosure to avoid asset seizure or criminal liability.

Timely filing is essential. Even if no tax liability arises from the accounts, the reporting obligation remains. FBAR is about transparency, not taxation.

Penalties & Enforcement

FBAR penalties are among the harshest in U.S. tax compliance. Under 31 U.S.C. § 5321(a)(5), civil penalties apply even for non-willful violations, while willful violations can trigger criminal charges.

• Non-Willful Violations: Up to $10,000 per violation, unless reasonable cause is proven.
• Willful Violations: Greater of $100,000 or 50% of the account balance at the time of violation.
• Criminal Penalties: Up to $250,000 in fines and/or 5 years imprisonment.

Enforcement is shared between the IRS and FinCEN. The IRS investigates and assesses penalties, while FinCEN oversees the BSA E-Filing system. Asset seizure prevention and voluntary disclosure programs are critical strategies for taxpayers facing exposure.

Case Study: A taxpayer with undisclosed Swiss accounts totaling $1 million faced a penalty of $500,000 (50% of account balance) for willful violation. This underscores the importance of timely compliance remediation.

FBAR vs Form 8938 (Comparison Engine)

FBAR (FinCEN Form 114) and IRS Form 8938 are often confused, but they serve distinct purposes. Both require disclosure of foreign assets, yet they differ in thresholds, filing methods, and enforcement agencies.

Feature	FBAR (FinCEN Form 114)	IRS Form 8938
Agency	FinCEN (Treasury)	IRS
Threshold	Aggregate foreign accounts > $10,000	Varies: $50,000 single / $100,000 joint (higher for expats)
Accounts Reported	Bank, brokerage, mutual funds, pensions	Specified foreign financial assets (broader scope)
Filing Method	BSA E-Filing system	Attached to Form 1040 tax return
Penalties	Up to $100,000 or 50% of account balance	$10,000 per violation; up to $50,000 for continued failure

Key Insight: Filing one does not substitute for the other. Many taxpayers must file both FBAR and Form 8938.

Step-by-Step Guide: Completing FBAR Form 114 (Line-by-Line)

This is a detailed, line-by-line walkthrough of FinCEN Form 114 in the BSA E-Filing system. We map each screen and field (“line”) so you can complete your FBAR accurately, avoid compliance remediation later, and reduce exposure to penalties. Where applicable, we note edge cases, currency conversion, joint ownership, signature authority, and amended filings.

1. Start your filing and select filing type

   Open the BSA E-Filing portal, create or sign in to your account, and start a new FinCEN Form 114. Select the proper filing year and filing type (Original or Amended). This sets the scope of your disclosure and determines whether you must complete a late filing explanation.

   • Line A — Filing year: Choose the calendar year you are reporting (e.g., 2024). FBAR always reports accounts for the prior calendar year.
   • Line B — Filing type: Select “Original” if first-time filing for the year; “Amended” to correct a previously submitted FBAR. If amended, include the prior BSA submission ID and specify what changed.
   • Line C — Late filing indication: If after October 15 (automatic extension deadline), mark “Late.” You will be prompted to enter a short explanation (reasonable cause) if applicable.
   • Line D — Consolidated filing: If filing for an entity with qualifying subsidiaries, indicate “Yes” and attach subsidiary list. Most individual filers select “No.”
   • Line E — 25+ accounts checkbox: If you have 25 or more reportable accounts, check this. You’ll provide summary-level information without listing each account. Retain detailed records for audit defense.

2. Complete filer identification (Part I)

   Enter your personal or entity information exactly as it appears on your U.S. tax records. Mismatches can trigger compliance review. For entities, use legal names as registered.

   • Line 1 — Filer type: Individual, Corporation, Partnership, LLC, Trust, or Estate. Choose “Individual” for personal filings.
   • Line 2 — TIN: SSN (for U.S. persons) or ITIN (if applicable). For entities, enter EIN. Do not leave blank.
   • Line 3 — Name: First, Middle (optional), Last, Suffix (if any). For entities, enter the full legal name.
   • Line 4 — Date of birth (individual only): Use MM/DD/YYYY.
   • Line 5 — Address: Street, City, State/Province, Postal code. If outside the U.S., include Country.
   • Line 6 — Contact info: Email and phone. Use a monitored inbox to receive the confirmation and any notices.
   • Line 7 — If other filer (authorized preparer): If a preparer is submitting on your behalf, include their contact information and keep Form 114a on file (FBAR e-file authorization).

3. Disclose each foreign account (Part II)

   For each reportable account, complete one account record. If you have fewer than 25 accounts, repeat this section until all accounts are entered. Report all accounts that existed at any time during the year.

   • Line 8 — Account type: Bank (deposit), Securities (brokerage), Other (e.g., mutual fund share account, certain pensions). Choose the closest fit.
   • Line 9 — Account number: Enter the full number as assigned by the institution. If unavailable, use a unique identifier provided by the bank.
   • Line 10 — Institution name: Full legal name of the foreign financial institution.
   • Line 11 — Institution address: Street, City, Province/Region, Postal code, Country. Accuracy matters for cross-border verification.
   • Line 12 — Maximum account value (USD): Report the highest balance during the year, converted to USD. Do not use year-end balance if the midyear peak was higher.
   • Line 13 — Currency and conversion: Convert using the U.S. Treasury’s published year-end exchange rates for the filing year. Keep your calculation and rate source on file for five years.
   • Line 14 — Account ownership: Individually owned, jointly owned, or signature authority only. Choose “Signature authority” when you can control disposition but do not own the funds.
   • Line 15 — Joint owner count: If jointly owned, indicate the number of joint owners and complete joint owner details (see Part III).
   • Line 16 — Account opened/closed dates: Provide if available. Closed accounts are still reportable if they existed and contributed to the threshold.
   • Line 17 — Country code: Select the account’s country of location (where the institution is licensed/regulated).

4. Provide joint owner details (Part III)

   If any account is jointly owned, FBAR requires basic identification for each joint owner. This ensures compliance transparency and prevents mismatched reporting.

   • Line 18 — Joint owner name: First, Middle (optional), Last; suffix if applicable.
   • Line 19 — Joint owner TIN: SSN, ITIN, or foreign tax ID if no U.S. TIN; note that not having a U.S. TIN does not negate reporting.
   • Line 20 — Joint owner address: Full mailing address, including country.
   • Line 21 — Ownership percentage: If known, indicate percentage; otherwise leave blank or “unknown.” Percentages do not change the need to report full maximum value.
   • Line 22 — Relationship to filer: Spouse, child, business partner, corporate co-signer, etc.

5. Report signature authority only (Part IV)

   If you do not own the account but have signature or other authority (e.g., CFO, controller, corporate officer), you must disclose those accounts. This is a distinct obligation from ownership.

   • Line 23 — Authority type: Signature authority, other authority (e.g., electronic authorization). Choose the applicable option.
   • Line 24 — Employer/organization name: The U.S. or foreign entity for whom you have authority.
   • Line 25 — Employer/organization address: Full address including country.
   • Line 26 — Account identifiers: Account number, institution name and address for each account over which you have authority.
   • Line 27 — Authority effective dates: Start and (if applicable) end date during the filing year.

6. Summarize total accounts and values (Part V)

   Provide a summary for the filing year. This helps the agencies reconcile your detailed entries with aggregate reporting requirements.

   • Line 28 — Total number of accounts reported: Count all ownership and signature authority accounts listed.
   • Line 29 — Aggregate maximum value (USD): Sum the maximum values of all reportable accounts after USD conversion. Do not net negative balances.
   • Line 30 — 25+ accounts summary: If you checked 25+ accounts earlier, provide total count and aggregate maximum value here and ensure you maintain detailed internal records.

7. Attestations, late explanations, and compliance statements

   Certify the filing’s accuracy and provide explanations if late or amended. This is where reasonable cause narratives can help mitigate non-willful exposure.

   • Line 31 — Certification statement: You affirm under penalties of perjury that the information is true, correct, and complete. Review before attesting.
   • Line 32 — Late filing explanation: If “Late,” enter a concise, factual explanation (e.g., records unavailable due to bank merger; relied on incorrect professional advice; medical incapacity). Avoid emotional language; focus on facts.
   • Line 33 — Amended filing explanation: Briefly describe the correction (e.g., added one omitted account; corrected maximum value after bank reissued statements).
   • Line 34 — Contact for follow-up: Confirm the email/phone where you can be reached regarding the filing.

8. Final review, submission, and recordkeeping

   Perform a meticulous review to prevent amendment later. Save your confirmation and maintain a defensible record set for five years. This supports audit readiness and asset seizure prevention strategies.

   • Line 35 — Cross-check identifiers: Verify TIN, names, addresses, and filing year across all sections.
   • Line 36 — Validate currency conversion: Confirm you used Treasury year-end rates and documented each conversion step (source, rate, date, calculation).
   • Line 37 — Consistency checks: Ensure total account count equals detailed entries; joint owner details present where required; signature authority accounts listed separately.
   • Line 38 — Submit electronically: Click submit and wait for the BSA E-Filing confirmation page and email. Save the BSA submission ID.
   • Line 39 — Retain records: Keep statements, conversion notes, joint owner communications, Form 114a (if applicable), and your submission receipt for at least five years.

Worked example: Maximum account value and conversion

Assume a EUR-denominated brokerage account peaked at €86,000 on June 12, then fell to €60,000 by year-end. FBAR requires the highest value during the year. Use the Treasury’s published year-end EUR→USD rate to convert €86,000 to USD for Line 12. Document the exact rate and computation. Do not use the midyear bank rate; FBAR standardizes conversion using Treasury year-end tables.

Special cases and edge lines

• Dormant/closed accounts: Report if the account existed during the year and contributed to crossing the $10,000 threshold. Include closed date in Line 16 if known.
• Pooled funds/mutual accounts: If the institution assigns a share/account number, report under “Other” type and include the institution’s regulatory domicile in Line 11.
• Corporate officers (signature authority): Provide employer information in Lines 24–25; do not report employer’s consolidated accounts as owned unless you have a financial interest.
• 25+ accounts: Use the summary option in Line 30. Maintain a granular ledger with each account’s maximum value, currency, and conversion notes.
• Reasonable cause (late): Keep supporting documentation (bank letters, medical records, merger notices) aligned with Line 32 narrative for penalty mitigation.
• Amendments: Specify changes in Line 33 and consider adding a short schedule (kept in your records) noting which account entries were corrected.

Pro-tips for line accuracy

• Uniform naming: Use exact institution legal names and addresses to avoid mismatch with international KYC databases.
• Peak balance sourcing: Pull monthly statements or transaction logs to identify the true maximum; do not estimate.
• TIN matching: Ensure the TIN in Line 2 matches your latest IRS filing to reduce follow-up queries.
• Audit trail: Save PDFs, CSVs, and email confirmations together with the BSA submission ID to streamline compliance remediation if questioned.
• Joint owner coordination: Align reported maximum values and owner details to avoid inconsistencies across multiple filers.

Hypothetical Scenarios

Understanding FBAR obligations is easier when applied to real-world examples. Below are scenarios that illustrate common filing complexities:

• CFO with multiple Hong Kong accounts: A U.S.-based CFO oversees 12 corporate accounts in Hong Kong. Even without personal ownership, signature authority requires disclosure in Part IV. Failure to report could trigger penalties despite no personal financial interest.
• Expat with joint account: A U.S. citizen living abroad shares a joint account with a non-U.S. spouse. The account peaked at $15,000. Both spouses must be disclosed in Part III, even if the spouse is not a U.S. person.
• Dormant account discovered: A taxpayer finds a forgotten Swiss account with $600. Combined with other accounts totaling $9,500, the threshold is exceeded. Dormant accounts are reportable under 31 CFR § 1010.350.

These scenarios highlight that FBAR is about transparency of access and authority, not just ownership or income.

Pro-Tips & Common Pitfalls

Pro-Tips

• Always use U.S. Treasury year-end exchange rates for currency conversion.
• Report accounts even if they generated no taxable income.
• Retain supporting documentation for five years to defend against audits.
• Coordinate with joint owners to ensure consistent reporting.
• Use compliance remediation programs if you discover missed filings.

Common Pitfalls

• Reporting year-end balance instead of maximum account value.
• Assuming FBAR is unnecessary if Form 8938 is filed.
• Failing to disclose signature authority accounts.
• Neglecting dormant or closed accounts that existed during the year.
• Submitting without retaining confirmation ID or records.

FAQ

Do I need to file FBAR if my account never exceeded $10,000?

No, FBAR is required only if the aggregate value of all foreign accounts exceeded $10,000 at any time during the year.

Is FinCEN Form 114 the same as FBAR?

Yes, FBAR is the common name for FinCEN Form 114, filed electronically via the BSA E-Filing system.

What is the difference between FBAR and Form 8938?

FBAR is filed with FinCEN and covers foreign accounts over $10,000. Form 8938 is filed with the IRS and has higher thresholds, covering broader foreign assets.

How do I amend FBAR Form 114?

Log into the BSA E-Filing system, select “Amended Filing,” enter the prior submission ID, and correct the relevant lines. Provide an explanation in Line 33.

What happens if I miss the FBAR deadline?

Late filings may trigger penalties. If non-willful, penalties can be waived with reasonable cause. Voluntary disclosure programs may mitigate exposure.

How do I calculate maximum account value?

Identify the highest balance during the year and convert it to USD using Treasury year-end exchange rates. Report this value in Line 12.

Is FBAR required for cryptocurrency?

Currently, FinCEN has not mandated FBAR reporting for cryptocurrency accounts, but guidance is evolving. Monitor updates closely.

Where can I download FBAR Form 114 PDF?

FBAR Form 114 is filed electronically, but a sample PDF is available on FinCEN’s website for reference.

Who enforces FBAR penalties?

The IRS enforces FBAR penalties, while FinCEN administers the filing system. Both agencies coordinate under the Bank Secrecy Act.

Conclusion

FBAR compliance is a critical obligation for U.S. persons with foreign accounts. By following the line-by-line instructions above, taxpayers can ensure accurate reporting, avoid costly penalties, and maintain transparency under the Bank Secrecy Act. Whether you are an expat, CFO, or high-net-worth individual, understanding how to complete FBAR form is essential to safeguarding your financial interests and meeting U.S. international tax requirements.